From Greentech Media:

The free-market think tank R Street Institute took a different approach to the legal issues. “RSI sees no defensible case to support the NOPR and as such, only provides comments on staff questions that relate to the ‘need to reform’ and an additional question on alternative options.”
Instead, the group weighed in on its area of expertise, saying the proposal “lacks empirical support for its claim that an emergency situation justifies massive, abrupt intervention that will likely cost consumers billions without any clear benefit.” R Street urged FERC to “pursue an alternative course to price reliability and resiliency services that enhances the competitive performance of organized wholesale electricity markets.”

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